Thomas A. Johnson - Page 2

                                          2                                           
               After concessions by the parties, the issues for decision              
          are:                                                                        
               (1) Whether petitioner had gross receipts during the                   
          taxable year 1988 from a business known as Ticketline.  We hold             
          that he did.                                                                
               (2) Whether petitioner has substantiated cost of goods sold            
          for Ticketline for the taxable year 1988.  We hold that                     
          petitioner has substantiated cost of goods sold in the amount of            
          $143,004.                                                                   
               (3) Whether petitioner is liable for self-employment tax               
          for the taxable year 1988 from his activities with Ticketline.              
          We hold that he is.                                                         
               (4) Whether the costs associated with petitioner's                     
          nutritional information system are deductible pursuant to section           
          174.  We hold that they are not.                                            
               (5) Whether petitioner is liable for the addition to tax               
          pursuant to section 6651(a)(1) for failure to file timely                   
          Federal income tax returns for the taxable years 1988 and 1989.             
          We hold that he is.                                                         
               (6) Whether petitioner is liable for the addition to tax               
          pursuant to section 6653(a)(1) for negligence for the taxable               
          year 1988.  We hold that he is.                                             
               (7) Whether petitioner is liable for the addition to tax               
          pursuant to section 6661 for a substantial understatement of tax            
          for the taxable year 1988.  We hold that he is.                             




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